Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Federal Pell Grant (ALN: 84.063); Federal Direct Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition:
The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect:
The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 7 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 1 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date.
• For 5 of 40 campus level records tested, the University did not accurately report the students’ enrollment status.
• For 1 of 25 program level records tested, the University did not accurately report the students’ program begin date.
• For 5 of 25 program level records tested, the University did not accurately report the students’ enrollment status.
• For 4 of 25 program level records tested, the University did not accurately report the students’ program length of study.
• For 2 of 25 program level records tested, the University did not accurately report the students’ CIP code.
• Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2023 fiscal year.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-002.
Recommendation:
We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS.
Views of Responsible Officials:
The Enrollment Reporting process is supervised by the University Registrar and is responsible for providing enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (“NSC”), who then submits the report to NSLDS student’s enrollment status. The University is committed to ensure sufficient training and support to the Office of the Registrar to keep the institution in compliance. While the expectation is the University will hire an experienced University Registrar and Associate Director Registrar for compliance, continued training opportunities will be made available through National Student Clearinghouse and NASFAA (National Association of Student Financial Aid Administrators).
The reported data is for students who are ¾ time during a semester, “3Q,” was discovered through testing of enrollment reporting samples to not be set up correctly in Banner. This has resulted in students who are taking between 9-11 credits being reported as “H” for half-time instead of “3Q” for three-quarter time. The newest University Registrar set up the “3Q” status correctly in Banner in January 2024 and testing of enrollment reporting samples show the 3Q status is accurate. The students in the program and campus-level findings should now be accurately reported as “3Q.”
After speaking with the Executive Director of Academic Planning and Curriculum, the CIP codes for the program identified as findings had not been updated when all CIP codes were updated in 2020. She also confirmed the length of the program was incorrectly published on the site for these programs. Howard has moved to Workday Student as the University’s Enterprise Resource Planning system and the accurate CIP codes and program lengths were confirmed. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday.
The University Registrar was not aware the FSA Audit testing exempt range of 07-19-2022 through 02-28-2024 required students who had an enrollment change during that period to be updated. This audit exemption range was abnormal, and the University hired a new Registrar during this time period, which resulted in there being no knowledge transfer the enrollment changes had not been updated. Graduation files are now being sent monthly to the National Student Clearinghouse to avoid students not being picked up for graduation as they are cleared.
Federal Program Information:
Federal Pell Grant (ALN: 84.063); Federal Direct Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition:
The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect:
The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 7 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 1 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date.
• For 5 of 40 campus level records tested, the University did not accurately report the students’ enrollment status.
• For 1 of 25 program level records tested, the University did not accurately report the students’ program begin date.
• For 5 of 25 program level records tested, the University did not accurately report the students’ enrollment status.
• For 4 of 25 program level records tested, the University did not accurately report the students’ program length of study.
• For 2 of 25 program level records tested, the University did not accurately report the students’ CIP code.
• Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2023 fiscal year.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-002.
Recommendation:
We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS.
Views of Responsible Officials:
The Enrollment Reporting process is supervised by the University Registrar and is responsible for providing enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (“NSC”), who then submits the report to NSLDS student’s enrollment status. The University is committed to ensure sufficient training and support to the Office of the Registrar to keep the institution in compliance. While the expectation is the University will hire an experienced University Registrar and Associate Director Registrar for compliance, continued training opportunities will be made available through National Student Clearinghouse and NASFAA (National Association of Student Financial Aid Administrators).
The reported data is for students who are ¾ time during a semester, “3Q,” was discovered through testing of enrollment reporting samples to not be set up correctly in Banner. This has resulted in students who are taking between 9-11 credits being reported as “H” for half-time instead of “3Q” for three-quarter time. The newest University Registrar set up the “3Q” status correctly in Banner in January 2024 and testing of enrollment reporting samples show the 3Q status is accurate. The students in the program and campus-level findings should now be accurately reported as “3Q.”
After speaking with the Executive Director of Academic Planning and Curriculum, the CIP codes for the program identified as findings had not been updated when all CIP codes were updated in 2020. She also confirmed the length of the program was incorrectly published on the site for these programs. Howard has moved to Workday Student as the University’s Enterprise Resource Planning system and the accurate CIP codes and program lengths were confirmed. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday.
The University Registrar was not aware the FSA Audit testing exempt range of 07-19-2022 through 02-28-2024 required students who had an enrollment change during that period to be updated. This audit exemption range was abnormal, and the University hired a new Registrar during this time period, which resulted in there being no knowledge transfer the enrollment changes had not been updated. Graduation files are now being sent monthly to the National Student Clearinghouse to avoid students not being picked up for graduation as they are cleared.
Federal Program Information: Federal Supplemental Educational Opportunity Grant (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition: Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame.
Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements.
Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. While amounts were within allowable thresholds, certain funds were overdrawn and held in excess of the allowable time frame.
Questioned Costs: None.
Context: One instance of excess cash that was not eliminated within the allowable time frame was identified for each of the University’s campus-based programs for the year ended June 30, 2023.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-004.
Recommendation: We recommend the University continue to enhance its procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to the Department of Education.
Views of Responsible Officials: The University will continue to provide additional information and training to personnel outside of the Office of Financial Aid. This information and training – where applicable – will be used to ensure that the University’s policies and procedures are in line with federal regulations and that internal policies and procedures do not supersede or impede federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grant (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition: Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame.
Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements.
Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. While amounts were within allowable thresholds, certain funds were overdrawn and held in excess of the allowable time frame.
Questioned Costs: None.
Context: One instance of excess cash that was not eliminated within the allowable time frame was identified for each of the University’s campus-based programs for the year ended June 30, 2023.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-004.
Recommendation: We recommend the University continue to enhance its procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to the Department of Education.
Views of Responsible Officials: The University will continue to provide additional information and training to personnel outside of the Office of Financial Aid. This information and training – where applicable – will be used to ensure that the University’s policies and procedures are in line with federal regulations and that internal policies and procedures do not supersede or impede federal regulations.
Federal Program Information:
Federal Pell Grant (ALN: 84.063)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting – Financial Reporting – Federal regulations require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”.
Condition:
For certain students identified through our testing, the University did not submit Federal Pell Grant payment data through the COD website within the required timeframes.
Cause:
Insufficient internal controls and administrative oversight resulted in the untimely reporting of certain Federal Pell Grant payment data.
Effect or Potential Effect:
The University is not in compliance with COD reporting requirements. Failure to submit and update COD records in a timely manner could result in improper awards of Title IV funds.
Questioned Costs:
None.
Context:
For 1 for 25 students selected for disbursement testing, the University did not report the Federal Pell Grant disbursements to COD within the required time frame.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University ensure that disbursement records are submitted to COD no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.
Views of Responsible Officials:
This student’s Pell disbursement was not reported within 15 days of disbursement due to the COD (Common Origination Disbursement) system rejecting the student’s disbursement. These Pell rejects are worked through the reconciliation process and this exception was not worked in a timely manner, resulting in COD accepting the disbursement past the 15-day deadline. The Howard University employee who was completing reconciliation of Title IV funds, as well as responsible for working through any Pell rejected disbursements is no longer employed at Howard.
The Assistant Director for Compliance works in the Office of Financial Aid and responsible for completing reconciliation and working any Pell rejected disbursements. The Associate Director for Compliance in Enrollment Management reviews reconciliations and ensures any rejected disbursements are resolved within the 15-day timeframe.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Federal Work-Study Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements to or on Behalf of Students – General Disbursement Criteria – Federal Work-Study Program – In accordance with 34 CFR 675.19(b)(2)(i), the institution must establish and maintain fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day.
Condition: Certain time records were prematurely approved by the students’ supervisors prior to performance of the work by the students.
Cause: Insufficiently designed internal controls and administrative oversight with respect to FWS disbursements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with recordkeeping requirements.
Questioned Costs: None.
Context: For 5 of 40 Federal Work-Study payments tested, the University reviewed and approved students’ timesheets before the time was incurred.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that student timesheets are appropriately reviewed.
Views of Responsible Officials: Federal Work Study supervisors are required to have training on the appropriate policies and procedures when hiring a Federal Work Study student. They will sign off on a document stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours. The student’s hours work may match the pay the student received and was approved for, but it is against policy to approve hours before the student worked. FWS supervisors will sign they understand this.
The Federal Work Study coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works and ensuring supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. Due to turnover in the department, a full-time FWS coordinator had not been hired and the person responsible for reviewing the hours worked had additional responsibilities outside of monitoring Federal Work Study. A full-time Federal Work Study Coordinator position has been approved and the anticipation is this position will be filled prior to the end of the Fall 2024 semester.
The Associate Director for Compliance will include a review of when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working-class hours. This plan to include when the supervisor approved the hours should provide another layer of oversight.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Highway Planning and Construction (ALN 20.205), Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements (ALN 20.237), State and Community Highway Safety Grants (ALN 20.600) and Mineta Consortium for Transportation Mobility (“MCTM”) (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
§ 200.516(4) and (6) requires the auditor to report the following as audit findings in a schedule of findings and questioned costs:
a) Known questioned costs greater than $25,000 for a Federal program that is not audited as a major program. Except for audit follow-up, the auditor is not required to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (for example, as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, the auditor must report this as an audit finding.
b) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of Generally Accepted Government Auditing Standards (“GAGAS”).
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year.
Questioned Costs:
$141,060.
Context:
As discussed in Finding 2023-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2023 that identified both the suspected abuse/misappropriation and the related questioned costs. Management’s investigation is ongoing and the appropriate law enforcement authorities have been notified. Additional questioned costs related to fiscal years prior to and subsequent to the year ended June 30, 2023 may be identified.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to university policies and grant terms. PRFs will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity involving PRFs, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
As part of the compliance program, quarterly audit samples will be conducted of PRFs and other high risk sponsored research transactions.
Federal Program Information:
Federal Pell Grant (ALN: 84.063); Federal Direct Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition:
The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect:
The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 7 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 1 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date.
• For 5 of 40 campus level records tested, the University did not accurately report the students’ enrollment status.
• For 1 of 25 program level records tested, the University did not accurately report the students’ program begin date.
• For 5 of 25 program level records tested, the University did not accurately report the students’ enrollment status.
• For 4 of 25 program level records tested, the University did not accurately report the students’ program length of study.
• For 2 of 25 program level records tested, the University did not accurately report the students’ CIP code.
• Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2023 fiscal year.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-002.
Recommendation:
We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS.
Views of Responsible Officials:
The Enrollment Reporting process is supervised by the University Registrar and is responsible for providing enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (“NSC”), who then submits the report to NSLDS student’s enrollment status. The University is committed to ensure sufficient training and support to the Office of the Registrar to keep the institution in compliance. While the expectation is the University will hire an experienced University Registrar and Associate Director Registrar for compliance, continued training opportunities will be made available through National Student Clearinghouse and NASFAA (National Association of Student Financial Aid Administrators).
The reported data is for students who are ¾ time during a semester, “3Q,” was discovered through testing of enrollment reporting samples to not be set up correctly in Banner. This has resulted in students who are taking between 9-11 credits being reported as “H” for half-time instead of “3Q” for three-quarter time. The newest University Registrar set up the “3Q” status correctly in Banner in January 2024 and testing of enrollment reporting samples show the 3Q status is accurate. The students in the program and campus-level findings should now be accurately reported as “3Q.”
After speaking with the Executive Director of Academic Planning and Curriculum, the CIP codes for the program identified as findings had not been updated when all CIP codes were updated in 2020. She also confirmed the length of the program was incorrectly published on the site for these programs. Howard has moved to Workday Student as the University’s Enterprise Resource Planning system and the accurate CIP codes and program lengths were confirmed. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday.
The University Registrar was not aware the FSA Audit testing exempt range of 07-19-2022 through 02-28-2024 required students who had an enrollment change during that period to be updated. This audit exemption range was abnormal, and the University hired a new Registrar during this time period, which resulted in there being no knowledge transfer the enrollment changes had not been updated. Graduation files are now being sent monthly to the National Student Clearinghouse to avoid students not being picked up for graduation as they are cleared.
Federal Program Information:
Federal Pell Grant (ALN: 84.063); Federal Direct Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition:
The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect:
The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 7 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 1 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date.
• For 5 of 40 campus level records tested, the University did not accurately report the students’ enrollment status.
• For 1 of 25 program level records tested, the University did not accurately report the students’ program begin date.
• For 5 of 25 program level records tested, the University did not accurately report the students’ enrollment status.
• For 4 of 25 program level records tested, the University did not accurately report the students’ program length of study.
• For 2 of 25 program level records tested, the University did not accurately report the students’ CIP code.
• Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2023 fiscal year.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-002.
Recommendation:
We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS.
Views of Responsible Officials:
The Enrollment Reporting process is supervised by the University Registrar and is responsible for providing enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (“NSC”), who then submits the report to NSLDS student’s enrollment status. The University is committed to ensure sufficient training and support to the Office of the Registrar to keep the institution in compliance. While the expectation is the University will hire an experienced University Registrar and Associate Director Registrar for compliance, continued training opportunities will be made available through National Student Clearinghouse and NASFAA (National Association of Student Financial Aid Administrators).
The reported data is for students who are ¾ time during a semester, “3Q,” was discovered through testing of enrollment reporting samples to not be set up correctly in Banner. This has resulted in students who are taking between 9-11 credits being reported as “H” for half-time instead of “3Q” for three-quarter time. The newest University Registrar set up the “3Q” status correctly in Banner in January 2024 and testing of enrollment reporting samples show the 3Q status is accurate. The students in the program and campus-level findings should now be accurately reported as “3Q.”
After speaking with the Executive Director of Academic Planning and Curriculum, the CIP codes for the program identified as findings had not been updated when all CIP codes were updated in 2020. She also confirmed the length of the program was incorrectly published on the site for these programs. Howard has moved to Workday Student as the University’s Enterprise Resource Planning system and the accurate CIP codes and program lengths were confirmed. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday.
The University Registrar was not aware the FSA Audit testing exempt range of 07-19-2022 through 02-28-2024 required students who had an enrollment change during that period to be updated. This audit exemption range was abnormal, and the University hired a new Registrar during this time period, which resulted in there being no knowledge transfer the enrollment changes had not been updated. Graduation files are now being sent monthly to the National Student Clearinghouse to avoid students not being picked up for graduation as they are cleared.
Federal Program Information: Federal Supplemental Educational Opportunity Grant (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition: Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame.
Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements.
Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. While amounts were within allowable thresholds, certain funds were overdrawn and held in excess of the allowable time frame.
Questioned Costs: None.
Context: One instance of excess cash that was not eliminated within the allowable time frame was identified for each of the University’s campus-based programs for the year ended June 30, 2023.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-004.
Recommendation: We recommend the University continue to enhance its procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to the Department of Education.
Views of Responsible Officials: The University will continue to provide additional information and training to personnel outside of the Office of Financial Aid. This information and training – where applicable – will be used to ensure that the University’s policies and procedures are in line with federal regulations and that internal policies and procedures do not supersede or impede federal regulations.
Federal Program Information: Federal Supplemental Educational Opportunity Grant (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition: Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame.
Cause: Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements.
Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. While amounts were within allowable thresholds, certain funds were overdrawn and held in excess of the allowable time frame.
Questioned Costs: None.
Context: One instance of excess cash that was not eliminated within the allowable time frame was identified for each of the University’s campus-based programs for the year ended June 30, 2023.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2022-004.
Recommendation: We recommend the University continue to enhance its procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to the Department of Education.
Views of Responsible Officials: The University will continue to provide additional information and training to personnel outside of the Office of Financial Aid. This information and training – where applicable – will be used to ensure that the University’s policies and procedures are in line with federal regulations and that internal policies and procedures do not supersede or impede federal regulations.
Federal Program Information:
Federal Pell Grant (ALN: 84.063)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting – Financial Reporting – Federal regulations require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”.
Condition:
For certain students identified through our testing, the University did not submit Federal Pell Grant payment data through the COD website within the required timeframes.
Cause:
Insufficient internal controls and administrative oversight resulted in the untimely reporting of certain Federal Pell Grant payment data.
Effect or Potential Effect:
The University is not in compliance with COD reporting requirements. Failure to submit and update COD records in a timely manner could result in improper awards of Title IV funds.
Questioned Costs:
None.
Context:
For 1 for 25 students selected for disbursement testing, the University did not report the Federal Pell Grant disbursements to COD within the required time frame.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University ensure that disbursement records are submitted to COD no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.
Views of Responsible Officials:
This student’s Pell disbursement was not reported within 15 days of disbursement due to the COD (Common Origination Disbursement) system rejecting the student’s disbursement. These Pell rejects are worked through the reconciliation process and this exception was not worked in a timely manner, resulting in COD accepting the disbursement past the 15-day deadline. The Howard University employee who was completing reconciliation of Title IV funds, as well as responsible for working through any Pell rejected disbursements is no longer employed at Howard.
The Assistant Director for Compliance works in the Office of Financial Aid and responsible for completing reconciliation and working any Pell rejected disbursements. The Associate Director for Compliance in Enrollment Management reviews reconciliations and ensures any rejected disbursements are resolved within the 15-day timeframe.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition: The University submitted the 2022-2023 FISAP with errors in the report and data corrections were not submitted by the required deadline. Additionally, the University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause: Insufficient internal controls and lack of sufficient administrative oversight resulted in data errors reported in the FISAP which were not subsequently corrected within the allowable time frame.
Effect or Potential Effect: The University is not in compliance with special reporting requirements.
Questioned Costs: None.
Context: The University submitted the annual FISAP for the 2022-2023 reporting year by the required deadline, however errors were subsequently identified within the report. As of the date of our Single Audit report, these errors remained uncorrected. Additionally, the University was unable to provide schedules and documentation supporting certain key line item amounts reported within the submitted FISAP.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its internal controls and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56).
Condition: The University was unable to provide documentation evidencing that verification was completed for a student. In addition, for a separate student the University provided documentation that appeared to be altered after it was completed.
Cause: Insufficient internal controls and administrative oversight with respect to verification procedures.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 1 of 18 students selected for verification testing, the University did not perform appropriate verification procedures.
• For 1 of 18 students selected for verification testing, the University initially provided verification documentation that appeared to be altered. The University was ultimately able to supply the appropriate documentation for that student to satisfy the testing requirements.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.
Views of Responsible Officials: The Assistant and Associate Director of Financial Aid will do a bi-semester review of V4 verification documents to ensure the updated policies and procedures are being followed. Financial Aid counselors have received training on this updated policy over two sessions in February 2024 and March 2024.
Federal Program Information: Federal Work-Study Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements to or on Behalf of Students – General Disbursement Criteria – Federal Work-Study Program – In accordance with 34 CFR 675.19(b)(2)(i), the institution must establish and maintain fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day.
Condition: Certain time records were prematurely approved by the students’ supervisors prior to performance of the work by the students.
Cause: Insufficiently designed internal controls and administrative oversight with respect to FWS disbursements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with recordkeeping requirements.
Questioned Costs: None.
Context: For 5 of 40 Federal Work-Study payments tested, the University reviewed and approved students’ timesheets before the time was incurred.
Identification as a Repeat Finding: No similar findings identified in the prior year.
Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that student timesheets are appropriately reviewed.
Views of Responsible Officials: Federal Work Study supervisors are required to have training on the appropriate policies and procedures when hiring a Federal Work Study student. They will sign off on a document stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours. The student’s hours work may match the pay the student received and was approved for, but it is against policy to approve hours before the student worked. FWS supervisors will sign they understand this.
The Federal Work Study coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works and ensuring supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. Due to turnover in the department, a full-time FWS coordinator had not been hired and the person responsible for reviewing the hours worked had additional responsibilities outside of monitoring Federal Work Study. A full-time Federal Work Study Coordinator position has been approved and the anticipation is this position will be filled prior to the end of the Fall 2024 semester.
The Associate Director for Compliance will include a review of when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working-class hours. This plan to include when the supervisor approved the hours should provide another layer of oversight.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 12 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-006.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (“OPC”) leadership attended a procurement with Federal Grants Seminar in November 2022. All OPC team members will be required to take mandatory foundational procurement training to close the knowledge gap and promote standardization and consistency. Procurement Managers will review all purchase orders over $25,000 before issuance to ensure the procurement record is complete to ensure that procurement is in alignment with the University’s Procurement Policy and procedures.
OPC revised the University’s Procurement & Contracting Policies, Procedures & Guidelines in September 2022 to include Uniform Guidance requirements to clearly define the procurement steps to take when processing requests at various dollar value thresholds. Also, a procurement checklist was developed to provide guidance pursuant to Uniform Guidance.
OPC established weekly office hours for PIs to receive guidance for all procurement activity (April 2024 – May 2024). OPC will host educational sessions to train Research Administrators and Principal Investigators on Procurement and Contracting requirements (October 2024 - May 2025). Grant Managers are part of the requisition approval workflow to review all documents including the SPO contractor/vendor justification/price verification form.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 3 of 7 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership or that appropriate property records were maintained.
• For 1 of 7 equipment items selected for testing, the federal asset identifier attached to equipment did not agree to identifier within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, no federal asset identifier was attached to equipment and no identifier was assigned within the University’s asset tracking system.
• For 1 of 7 equipment items selected for testing, a federal asset identifier was attached to the equipment, but no identifier was assigned with the University’s tracking system.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-007.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
Equipment purchased with federal funds will be maintained in the Workday property management system by Procurement and Grants and Contracts. Procurement will tag equipment when initially received at Howard University Central Receiving. An additional process will be implemented to ensure equipment delivered directly to departments will be timely tagged. Workday property records include fields for the equipment description, relevant identification numbers, source, title information, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and ultimate disposition data.
In conjunction with Grants and Contracts, the Office of Procurement and Contracting is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, Grants and Contracts forwards a report to the Office of Procurement and Contracting listing all assets that are missing a tag number in the system. The Office of Procurement must then track down each item on the list and either tag the item or update the asset in the system with the tag number.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 8 Research and Development Cluster publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-008.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
Action Steps:
1. Communication
a. Create Current Researcher Email List Serv for distribution of information/reminders.
b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements.
c. We will distribute information regarding this finding to our researchers every quarter via the listserv.
d. Completion: The first distribution will occur on October 1, 2024
2. Develop Training Materials
a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications.
b. Include examples of compliant and non-compliant publications.
c. Completion: Second Quarter of FY 2025
3. Campus-Wide Training
a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method.
b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project.
c. Completion: Second Quarter of FY 2025
4. Award Specific Training
a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator.
b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings.
5. Ongoing Monitoring and Compliance
a. Maintain records of all training attendance.
b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications.
c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements.
d. Non-compliant Faculty will not be able to submit proposals if training is delinquent.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship Program (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CRF Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities and F&A cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. After-the-fact Activity Records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included; (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements.
For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods.
Condition:
For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s effort certification process.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 40 Research and development cluster employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
• For 3 of 16 Thomas R. Pickering employee pay periods selected for testing, an effort certification supporting the employees’ payroll costs was not completed timely.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-012.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately monitoring time of effort reporting in a timely manner.
Views of Responsible Officials:
The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding.
A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary.
Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions.
Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Provider Relief Fund (ALN: 93.498) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Reporting - The University is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the University may be required to submit performance reports at least annually but not more frequently than quarterly. Additionally, if required based on the terms of the grant agreement, the University should submit financial reports that are complete, accurate, and prepared in accordance with the required accounting basis. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards.
Condition:
The University is not in compliance with certain reporting requirements. Certain progress and financial reports were not submitted in a timely manner.
Cause:
Insufficient internal controls, inadequate monitoring of policies and procedures and administrative oversight with respect to reporting requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the Reporting compliance requirements and certain progress and financial reports were not submitted timely.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 1 of 6 Thomas R. Pickering reports selected for testing, the quarterly financial report submitted did not agree to university’s accounting records.
• For 1 of 1 Provider Relief Fund report selected for testing, the annual financial report submitted did not agree to university’s accounting records.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-010.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University prepares and submits required federal reporting in accordance with Uniform Guidance and applicable grant agreements.
Views of Responsible Officials:
Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s) and Thomas R. Pickering Fellowship (ALN:19.013)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – per 2 CFR Part 200.302, the recipient's and subrecipient's financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.
Condition:
The University is not in compliance with certain allowable cost/cost principle requirements. Certain expenditure amounts did not agree to source documentation. Certain expenditures recorded to grant with insufficient funds.
Cause:
Insufficient internal controls and administrative oversight with respect to review of federal
expenditures for allowable costs.
Effect or Potential Effect:
Inadequate monitoring of policies and procedures and administrative oversight with respect to review of federal expenditures for allowable costs.
Questioned Costs:
Below reporting threshold.
Context:
• For 1 of 25 Research and Development Cluster expenditure selected for testing, expenditure was charged to grant award which was not appropriately supported by source documentation.
• For 1 of 25 Thomas R. Pickering fellowship expenditure selected for testing, expenditure amount recorded in recipient financial system was not appropriately supported by source documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2022-014.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University retains appropriate documentation supporting federal expenditures.
Views of Responsible Officials:
The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”).
The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined.
All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity.
The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations.
The internal controls will be updated by December 2024 and training will commence in early 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.403, the University shall monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.
Condition:
The University is not in compliance with certain subrecipient monitoring conditions as required. Subrecipient invoices not reviewed by the University or review was not performed within required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to the University’s subrecipient monitoring process.
Effect or Potential Effect:
The University was not in compliance with certain subrecipient monitoring requirements during the year.
Questioned Costs:
None.
Context:
We noted the following in during our testing:
• For 4 of 25 subrecipient invoices selected for testing, no evidence of invoice review or sign off completed by the university.
• For 2 of 25 subrecipient invoices selected for testing, invoice date shows expenditure was related to a prior period expense.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University is appropriately and timely monitoring its subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025.